Foreign Corrupt Practices Act Violations

SEC Whistleblower Reward Program Information

Whistleblowers could receive sizeable rewards through the Securities and Exchange Commission’s whistleblower reward program for providing the government with information about violations of the Foreign Corrupt Practices Act (FCPA).

The FCPA prohibits U.S. companies and individuals from paying money or any other sort of inducement to a foreign official to influence a decision or action affecting that company’s business.

“. . . Offshore does not mean off-limits," said Robert Khuzami, the SEC's enforcement director, in a statement issued about an FCPA case.

The SEC and the Department of Justice, which jointly enforce the anti-bribery law, have become much more aggressive in recent years about pursing foreign bribery cases. Whistleblowers can play a key role in that enforcement effort and collect a reward from the SEC. Under the provisions of the Dodd-Frank Act, whistleblowers are entitled to 10 percent to 30 percent of the amount recovered in FCPA cases and cases involving other SEC violations.

Corporations have paid huge sums to settle FCPA cases. Siemens Corp. set a record when it paid $800 million to settle an FCPA case.

Congress passed the Foreign Corrupt Practices Act in 1977, partially as a result of two separate cases against Northrop Corp. and Phillips Petroleum brought by one of Phillips & Cohen’s founding partners and his public interest law firm that exposed the use of corporate funds to pay bribes in foreign countries.

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